STATE OF CONNECTICUT

DEPARTMENT OF ENVIRONMENTAL PROTECTION

The State of Connecticut and

Pfizer, Inc

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Trading Agreement

and Order No. 8136 A

Whereas, the Commissioner ofEnvironmental Protection ("Commissioner") and

Pfizer, Inc. ("Pfizer") agree that it is in the public interest that they work cooperatively

to improve the air quality within the State of Connecticut and that the use of discrete

emission reduction credit ("DERe") trading to reduce nitrogen oxide (''NOx'')

emissions will achieve this result in a timely and cost-effective manner.

A. At the request and with the agreement of Pfizer, the Commissioner finds the

following:

1. This Trading Agreement and Order 5upercedes Trading Agreement and Order

8136 issued on April 29, 1999, Trading Agreement and Order 8136 Addendum I

issued on December 5, 2001, and Trading Agreement and Order 8136 Addendum

2 issued on April 29, 2002. With respect to future creation and use for boiler 4,

this Trading Agreement and Order supercedes Trading Agreement and Order

8093B issued on December 5, 2001 and Trading Agreement and Order 8093B

Addendum I issued on April 29, 2002.

2. Pfizer is a corporation that owns and operates a pharmaceutical production and

research facility at Eastern. Point Road, Groton, Connecticut ("facility").

3. At the facility, Pfizer owns and operates fuel burning equipment which consists of

four (4) steam boilers numbered 1,2,3 and 4 {"boilers") capable ofburning

natural gas or No.6 fuel oil, which are the subject of this Trading Agreement and

Order, and are subject to Section 22a-174-22 ofthe Regulations pertaining to the

control of NOx emissions.

4. Pfizer monitors NOx emissions from each boiler using continuous emissions

monitors ("CEMs''), certified to 40 Code of Federal Regulations Part 60.

5. Pfizer sometimes exceeds the NOx allowable emission rate limits in Section 22a174-22 ofthe Regulations.

6. To reduce NOx emissions from the boilers to below the limitations established by

Section 22a-174-22(e) of the Regulations Pfizer frequently bums natural gas.

(Printed on Recycled Paper)

79 Elm Slreet . Hafliord. CT 06105·5127

An ~o:Jotl O;>potTUflIIY employer • hllP /Idep SlotlE elliS

Celebrating a Century of Forest Conservarion Leadership

1901 2001
Pfizer, Inc. 2 Trading Agreement

and Order No. 8136 A

7. The emissions trading baseline ("baseline emission rate") for the boilers is 0.25

IbslMMBtu of heat input when operating on No.6 fuel oil and 0.20 lbsIMMBtu of

heat input when operating on natural gas. Said baseline emission rates are based

on approved emissions tests conducted in 1996 and 1997.

8. In the funue Pfizer intends to use 1\0. 2 fuel oil. The baseline emission rate for

the boilers is 0.20 IbsIMMBtu of heat input when operating on No.2 fuel oil.

9. Pursuant to Sectil(n'22a-174-22(j) ofthe Regulations, Pfizer proposes to generate

approved DERCs and to comply with Section 22a-174-22(e) of the Regulations

through the use of approved DERCS until Apri130, 2007, at the facility in

accordance with this Trading Agreement and Order.

10. When properly documented by Pfizer, and approved by the Commissioner, the

emission reductions identified above, and as computed in accordance with the

terms ofthis Trading Agreement and Order, will conform to the requirements of

Section 22a-174-22(j)(3) of the Regulations. SpecificaIly, the reductions wiIl be:

Real because they will result in a reduction of actual emissions released into the

air, net of any consequential increase in actual emission resulting from shifting

demand. The emission reductions will be properly measured, recorded, and

reported.

Quantifiable because they are based on CEM data as applied to an appropriate

reliable and replicable protocol, providing the rate and total mass amount of

reduction.

Surplus because they ar~ not required by any Connecticut statute or regulation

mandated by a current State Implementation Plan ("SIP"), and are not relied upon

in any applicable attainment plan, any reasonable further progress plan, milestone

demonstration or applicable federal regulation.

Permanent because the 10w-NOx burners will be in place and operating, and an

appropriate tracking system is in place to monitor all data required to verify and

quantify the creation ofDERCs.

Enforceable because the DERCs are approved by the Commissioner

retrospectively after the submission by Pfizer of a report that documents their

creation.

II. The Commissioner, in accordance with the provisions ofTrading Agreement and

Order No. 8136, Order 8093B and Addendum I, pursuant to Section 22a-174-

22(j) of the Regulations, approved the NOx DERCs referenced in Table 1 ofthis

Trading Agreement and Order. DERC creation serial numbers assigned by the

Department to these previously approved DERCs are provided in Table 1 of this
Pfizer, Inc. 3 Trading Agreement

and Order No. 8136 A

·3

Trading Agreement and Order. These remaining DERCs, to the extent they are

unused, are subject to the vintage restrictions ofthis Trading Agreement and

Order. Dates after which the unused DERCs will no longer be eligible for use as

a result of the vintage restrictions are provided in Table 1 ofmis Trading

Agreement and Order in the expiration date column.

Table 1

PreviouslY AQoroved (to the extent not alreadv used) DERCs

Year of Ozone season NQx DERC Ozone Non-ozone season NOx Non- Expiration

Generation serial numbers season DERC serial numbers ozone Date

NO. season

DERCs NO.

DERC

5/31/96- CT98/8136(DC)NOxnzl-35 35 N/A NlA 12/31/04

9130198

5131/96- O98/8093A(DC)NOxozl-44

1

44 1 N/A N/A 1 '213 1/04

9130198

1998 I O9818093B DC)NOxnzl-2 I 2 IN/A IN/A I 11J3I104

1999 CT99/8136(DC)NOxozl-l0 10 Cf99/8136{DC)NOxnoz8·11 4 12/31/04

1999 Cf99/S093B(DC)NOxQZ1-8 8 N/A NlA 12/31/04

2000 CToo/8136(DC)No.oz 1-15 15 crOO/8136{DC)NOxnoz 1-8 8 12/31/05

2000 N/A CTOO/81 36{DC)NOxnoz9 1 12131/05

2000 CT00I8093BIDC)No.ozl-8 I 8 IN/A N/A IWII05

2001 I CT01/8136(DC)NOxoz3-16 114 t CfOl/8136(DC)NOxnozl-2 2 I 12131/06

2001 I CT01/8093B(DC)NOxozl-11 I 11 J N/A N/A I 12131/06

B. The Commissioner, in accordance with the provisions ofthis Trading Agreement

and Order, pursuant to Section 22a-174-22(j) of the Regulations, hereby allows

Pfizer to:

1. Comply with Section 22a-174-22(d) of the Regulations through use ofDERC

trading; and

2. Upon sufficient documentation as prescribed in this Trading Agreement and

Order, generate additional DERCs. Upon issuance of an addendum to this

Trading Agreement and Order the Commissioner may approve the generation of

additional DERCs by Pfizer retrospectively. Approved DERCs generated by

Pfizer may be held by Pfizer or transferred to other persons in accordance with

this Trading Agreement and Order.

c. . With the agreement of Pfizer, the Commissioner, acting under Sections 22a-6,

22a-171, 22a-174, 22a-176, and 22a-177 of the Connecticut General Statutes,

hereby orders Pfizer as follows:

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1. Upon issuance ofthis Trading Agreement and Order, Pfizer may generate

approved DERCs as allowed under this Trading Agreement and Order until April

30,2007.
Pfizer, Inc. 4 Trading Agreement

and Order No. 8136 A

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2. Upon issuance of this Trading Agreement and Order, at the facility, Pfizer shall

comply with Section 22a-174-22 of the Regulations through emission reduction

trading. Until Pfizer achieves permanent compliance with the emission standard

in Section 22a-174-22(e) of the Regulation or by April 30, 2007, whichever

occurs earlier:

a. Pfizer shall use approved DERCs as required under this Trading

Agreement and Order; and

,

b. Pfizer shall have in its possession sufficient approved DERCs to meet

applicable NOx emission limits as allowed under this Trading Agreement

and Order.

3. DERC Generation.

a. Until April 3D, 2007, when the boiler has daily NOx emissions below the

applicable baseline emission rate(s), or the proportioned baseline emission

rate, Pfizer shall calculate the amount ofDERCs generated as follows:

DERCs (tons) generated {[Total heat input of all fuels in MMBtu x

«(proportioned baseline emission rate) - (the CEM-recorded NOx emission

rate))] + 2000 Ibs/ton} x (0.90).

1. When calculating DERCs, to detennine heat input Pfizer shall use

the actual fuel usage data for the boilers in MMBtuiday. Tne CEMrecorded Ox emission rates shall be calculated pursuant to the

methodology described in 40 Code ofFedera! Regulations Pan 60.

11. The baseline emission rate shall be calculated by 1)multiplying the

heat input of each fuel combusted by the baseline emission rate(s)

for such fuel; 2) swnming those products; and 3) dividing the sum

by the total heat input. If the boiler is operating exclusively on one

fuel, Pfizer may replace the proportioned baseline emission rate

with the applicable baseline emission rate, for that fuel. Pfizer

shall use 0.25 IbsIMMBtu of heat input when operating on No.6

fuel oil and 0.20 IbsIMMBtu of heat input when operating on

natural gas as the baseline emission rates for the boilers, or the

proportioned baseline emission rate when simultaneously operating

on more than one fuel.

Ill. Ten (10) percent of all DERCs (tons) generated by the boilers shall

be retired by Pfizer and pennanently removed from all calculations

on a monthly basis to assure a benefit to the environment.

b. When the daily or non-ozone season CEM-recorded NOx emission rate is

used to calculate DERCs generated by the boilers, Pfizer shall not include
Pfizer, inc. 5 Trading Agreement

and Order No. 8136 A

missing data calculated in accordance with any missing data substitution

procedures, including those allowed under Section 22a-174-22a of the

Regulations.

c. In order to consider a Daily NOx Averaging Period valid for DERC

approval, it must contain valid data hours for seventy-five (75%) ofthe

operating hours in that daily period (example: minimum 18 valid hours for

a full 24-hour operating say; minimum 12 hours for 16 operating hours,

etc.). A Daily NOx Averaging Period is defined as the total of all

operating bours in a day during whieb fuel is being fed to the boile".

Additionally, for a data hour to be considered a valid hour, seventy-five

percent (75%) minimum data capture requirements much be met for each

one-bour block period. All NOx and CO,IO, CEMs must comply witb 40

Code ofFederal Regulations Part 60 Appendix F drift criteria.

d. In requesting approval ofDERCs generated by the boilers, Pfizer shall

provide docwnentation containing a sample spreadsheet with calculation

formulas used to detennine reponed numbers; monthly operating reports

of actual fuel usage including the fuel BTU content, for each fuel type;

daily MMBtu for eaeb fuel type and actual beat input based upon CEMrecorded data; daily actual NOx emission rates (24-hour average); and

DERCs generated using the baseline emission rate(s), or the proportioned

baseline emission rate, net ofthe environmental discounts.

e. Requests for approval of all DERCs generated by Pfizer under this

Trading Agreement and Order shall be submitted in writing to the

Commissioner. Such requests may be compiled on a monthly or seasonal

basis and shall be submitted at least on an annual basis. Approved DERCs

generated by Pfizer under this Trading Agreement and Order may be held

or transferred to other persons and shall remain valid until they are used or

until their vintage expiration date, whichever occurs first.

4. DERC Use. Until April 30, 2007, before the fi"t day of eaeb month Pfizer

shall have in its possession sufficient approved DERCs for such month based

on the following calculation.

a. Before the first day of each month, Pfizer shall estimate DERCs required

for such calendar month for the boilers as follows:

Estimated DERCs (tons) = {[Estimated NOx emission rate in Ibs/MMBtu

- ((0.95) x (NOx baseline emission limit or

proportioned baseline emission rate calculated

pursuant to Section 22a-I74-22(f)(2)(A) oftbe

Regulations in Ibs/MMBtu))] x (Estimated fuel

use in MMBtu)} • 2000 Ibs/ton.
Pfizer, Inc. 6 Trading Agreement

and Order No. 8136 A

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5.

6.

b. No later than the twentieth day of each month, Pfizer shall calculate the

actual DERCs used in the preceding calendar month, as follows:

DERCs (tons) used~ {[(CEM-recorded NOx daily average emission rate

in IbsIMMBru*) - ((0.95) x (NOx baseline emission limit or proportioned

baseline emission rate calculated pursuantlo Section 22a-174-22(f)(2)(A)

ofthe Regulations in IbsIMMBru))] x (acrual fuel use in MMBru)) .,. 2000

Ibs/ton.

*This rat~'shall be calculated pursuant to the methodology described in 40

CFRPart 60.

c. When calculating the daily NOx DERCs used by the boilers, Pfizer shall

average all valid NOx CEM-recorded readings in a day.

Record Keepine. Pfizer shall make and keep records for the boilers of: daily

fuel use and fuel type; the actual NOx emission rates (24-hour average),

number of operating hours per day, the number of invalid data hours ofthe

total operating hours per day; the number ofDERCs created and used each

day in accordance with the appropriate emission rates and limits in this

Trading Agreement and Order; the number ofDERCs in its possession and

purchased (by serial number if assigned.) each month; the number ofDERCs

used during the ozone season and non-ozone season (the remainder ofthe

year); as well as documentation arresting to the fact that approved DERCs

used during the ozone season were generated during the ozone season.

Generator certification ofthis fact shall be sufficient. Pfizer shall maintain

such records to the Commissioner in accordance with Section 22a-174-22 of

the Regulations. Pfizer shall retain records and supporting documentation as

described in this Trading Agreement and Order for a minimum offive years,

commencing on the date such records were created. Pfi2;er shall provide the

records specified above to the Commissioner within thirty (30) days of

receipt of a written request ,from the Commissioner.

Annual Emission Statement. No later than March 1 of every year after

issuance ofthis Trading Agreement and Order, Pfizer shall include with the

Annual Emission Statement provided to the Commissioner, a record of each

sale or other transfer, and use of any and all ofthe DERCs approved within

and subsequent to issuance of this Trading Agreement and Order until all

such DERCs have been used or are no longer in Pfizer's possession. Pfizer

shall also include actual. Ox emissions from each of the boilers and the

amount of all approved DERCs used (including serial numbers (if assigned)

and approved DERCs generated andlor purchased from other facilities),

generated andlor approved for the previous calendar year. These repom shall

be on a fonn prescribed by the Commissioner and shall be in monthly

Increments. Should Pfizer choose to discontinue the generation ofDERCs,
Pfizer, Inc. 7 Trading Agreement

and Order No. 8136 A

Pfizer will notify the Commissioner upon discontinuance.

7. Allowance Use. Pursuant to Section 22a-174-22(d)(3) of the Regulations, Pfizer

may use NOx allowances, pursuant to Section 22a-174-22(j) of the Regulations to

achieve all or a ponion of the reductions required by Section 22a-174-22 of the

Regulations. Any allowance used for compliance with Section 22a-174-22(e) of

the Regulations shall be subject to all restrictions and/or requirements applicable

to DERCs contained in this Trading Agreement and Order. Each allowance used

for compliance witli Section 22a-174-22 of the Regulations shall be equivalent to

one DERC and sb'all be deducted from Pfizer's NOx Budget Program compliance

account upon such use. Allowances shall be considered used for compliance with

Section 22a-174-22 of the Regulations when they are transferred from the

facility's compliance account or overdraft account to a State ofConnecticut NOx

allowance retirement account, account ID CTOO00000300 in the Ox Allowance

Tracking System (NATS).

8. DERC Doublin2. At a minimum, approved DERCs required for compliance with

this Trading Agreement and Order shall be adjusted upwards by 100% ifDERCs

are not in Pfizer's possession prior to the first day of each month. However,

based on the gravity ofthe noncompliance, the Commissioner may require

additional upward adjustment.

9. Vintage Restriction. For the purposes of compliance with Section 22a-174-

22 ofthe Regulations, DERCsiallowances shall only remain valid for five (5)

calendar years from the year ofthe generation/allocation ofsuch

DERCs/allowances. DERCs/allowances generated/allocated more than five

(5) calendar years ago are not valid for use for compliance with Section 22a174-22 of the Regulations. Notwithstanding the above the

DERCsiallowances generated/allocated prior to calendar year 2000 shall be

valid for use until December 31, 2004.

10. Extension. No later than April 30, 2007, with respect to the boilers, Pfizer

shall comply with the requirements ofSection 22a-174-22(d)(I) ofthe

Regulations. However, after full program review of this and other Trading

Agreements and Orders and, if detennined to be appropriate, the

Commissioner may grant a written extension of this Trading Agreement and

Order.

II. Furore Comnliance RecoI1. On or before September I, 2006, Pfizer shall

submit a report indicating how the facility shall comply with Section 22a174-22 of the Regulations with respect to the boilers on and after May I,

2007.

12. Full compliance. Pfizer shall not be considered in full compliance with this

Trading Agreement and Order until all actions required by this Trading
Pfizer, Inc. 8 Trading Agreement

and Order No. 8136 A

Agreement and Order have been completed as approved and to the

Commissioner's satisfaction.

13. Approvals. Pfizer shall use best efforts to submit to the Commissioner all

documents required by this Trading Agreement and Order in a complete and

approvable fonn. Ifthe Commissioner notifies Pfizer that any document or

other action is deficient, and does not approve it with conditions or

modifications, it is deemed disapproved, and Pfizer shall correct the

deficiencies and ~dubmit it within the time specified by the Commissioner

or, if no time is specified by the Commissioner, within 30 days of the

Commissioner's norice of deficiencies. In approving any document or other

action under this Trading Agreement and Order, the Commissioner may

approve the docwnent or other action as submitted or perfonned or with such

conditions or modifications as the Commissioner deems necessary to carry

out the purposes ofthis Trading Agreement and Order. Nothing in this

paragraph shall excuse noncompliance or delay.

14. Definitions. As used in this Trading Agreement and Order, "Approved

DERCs" are those for which the Commissioner has provided written

authorization for use in compliance with Section 22a-174-22 ofthe

Regulations; "Commissioner" means the Commissioner or a representative of

the Commissioner; "Ozone season" means the period from May I through

September 30 in any given calendar year. The date of "issuance" ofthis

Trading Agreement and Order is the date the Trading Agreement and Order

is deposited in the U.S. mail or personally delivered, whichever is earlier.

15. Dates. The date ofsubmission to the Commissioner of any document

required by this Trading,Agreement and Order shall be the date such

document is received by the Commissioner. The date of any notice by the

Commissioner under Trading Agreement and Order, including but not limited

to notice of approval or disapproval of any docwnent or other action, shall be

the date such notice is deposited in the U.S. mail or is personally delivered,

whichever is earlier. Except as otherwise specified in this Trading

Agreement and Order, the word "day" as used in this Trading Agreement and

Order means calendar day. Any docwnent or action which is required by this

Trading Agreement and Order to be submitted or performed by a date which

falls on a Saturday, Sunday or a Connecticut or federal holiday shall be

submitted or performed by the next day which is not a Saturday, Sunday or

Connecticut or federal holiday.

16. Certification of documents. Any document, including but Dot limited to any

notice, which is required to be submitted to the Commissioner under this

Trading Agreement and Order shall be signed by PfLZer or, if Pfizer is not an

individual, by Pfizer's chief executive officer or a duly authorized

representative ofsuch officer, as those terms are defined in Section 22a-430-
Pfizer, Inc. 9 Trading Agreement

and Order No. 8136 A

3(b)(2) of the Regulations ofConnec!icut State Agencies, and by the

individual(s) responsible for actually preparing such docwnent, and Pfizer or

Pfizer's chief executive officer or a duly authorized representative ofsuch

officer, and each such individual shaH certify in writing as follows:

"I have personally examined and am familiar with the information submitted in

this docwnent and all anaclunents thereto, and I certify, based on reasonable

investigation, including my inquiry of those individuals responsible for obtaining

the information,.thct1: the submitted information is true, accurate and complete to

the best ofmy laiowledge and belief. I understand that any false statement made

in the submined information is punishable as a criminal offense under Section

53a-157b ofthe Cormecticut General Statutes and any other applicable law."

17. Noncompliance. This Trading Agreement and Order is a final order ofthe

Commissioner with respect to the matters addressed herein, and is

nonappealable and inunediately enforceable. Failure to comply with this

Trading Agreement and Order may subject Pfizer to an injunction and

penalties.

,,,,\, J

18. False statements. Any false statement in any information submitted pursuant

to this Trading Agreement and Order is punishable as a criminal offense

under Section 53a-157b of the Connecticut General Statutes and any other

applicable law.

19. Notice of transfer: liability ofPfizer. Until Pfizer has fully complied with

this Trading Agreement and Order, Pfizer shall notify the Corrunissioner in

writing no later than 15 days after transferring all or any portion ofthe

facility, the operations, the site or the business which is the subject ofthis

Trading Agreement and Order or after obtaining a new mailing or location

address. PfIzer's obligations under this Trading Agreement and Order shall

not be affected by the passage of title to any property to any other person or

municipality.

i. j

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20, Commissioners powers. Nothing in this Trading Agreement and Order shall

affect the Commissioner's authority to institute any proceeding or take any

other action to prevent or abate violations oflaw, prevent or abate pollution,

recover costs and natural resource damages, and to impose penalties for past,

present, or future violations of law. Ifat any time the Commissioner

determines that the actions taken by Pfizer pursuant to this Trading

Agreement and Order have not successfully corrected all violations, fully

characterized the extent or degree of any pollution, or successfully abated or

prevented pollution, the Commissioner may institute any proceeding to

require Pfizer to undertake further investigation or further action to prevent or

abate violations or pollution.
Pfizer, Inc. 10 Trading Agreement

and Order No. 8136 A

"

21. Pfizer's obli£ations under law. Nothing in this Trading Agreement and Order

shall relieve Pfizer of other obligations under applicable federal, state and

local law.

22. No assurance bv Commissioner. No provision of this Trading Agreement

and Order and no action or inaction by the Commissioner shall be construed

to constitute an assurance by the Commissioner that the actions taken by

Pfizer pursuant to this Trading Agreement and Order will result in

compliance or pr~vbnt or abate pollution.

23. Access to premises. .Any representative ofthe Department ofEnvironmental

Protection may enter the premises without prior notice for the purposes of

monitoring and enforcing the actions required or allowed by this Trading

Agreement and Order.

24. No effect on rights of other persons. This Trading Agreement and Order

neither creates nor affects any rights of persons or municipalities that are not

parties to this Trading Agreement and Order.

25. No Creation ofPropenv Rights. This Trading Agreement and Order does not

create any property rights with respect to these DERCs.

26. Notice to Commissioner of changes. Within 15 days of the date Pfizer

becomes aware of a change in any information submitted to the

Commissioner under this Trading Agreement and Order, or that any such

information was inaccurate or misleading or that any relevant information

was omitted, Pfizer shall submit the correct or omitted information to the

Commissioner.

27. Notification of noncompliance. In the event that Pfizer becomes aware that it

did not or may not comply, or did not or may not comply on time, with any

requirement of this Trading Agreement and Order or of any document

required hereunder, Pfizer shall immediately notify by telephone the

individual identified in the next paragraph and shall take all reasonable steps

to ensure that any noncompliance or delay is avoided or, if unavoidable, is

minimized to the greatest extent possible. Within five (5) days ofthe initial

notice, Pfizer shall submit in writing the date, time, and duration of the

noncompliance and the reasons for the noncompliance or delay and propose,

for the review and written approval of the Commissioner, dates by which

compliance will be achieved, and Pfizer shall comply with any dates which

may be approved in writing by the Commissioner. Notification by Pfizer

shall not excuse noncompliance or delay, and the Commissioner's approval of

any compliance dates proposed shall not excuse noncompliance or delay

unless specifically so stated by the Commissioner in writing.
Pfizer, Inc. II Trading Agreement

and Order. TO. 8136 A

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28. Submission of documents. Any document required to be submined to the

Commissioner under this Trading Agreement and Order shall, unless

otherwise specified in this Trading Agreement and Order or in writing by the

Commissioner, be directed to:

Mrs. Elizabeth McAuliffe

Department of Envirorunental Protection

Bureau ofAir Management

Compliance and Field Operations Division

Emissions and Credit Trading Section

79 Elm Street

Hartford, Connecticut 06106
Pfizer, Inc. 12 Trading Agreement

and Order No. 8136 A

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Pfizer consents to the issuance of this Trading Agreement and Order without funher

notice. The undersigned cenifies that he/she is fully authorized to enter into this Trading

Agreement and Order and to legally bind Pfizer to the terms and conditions ofthe

Trading Agreement and Order.

Signature: -~bD'ili1=t~ ~~"l:l~:::::::='_2 _

Type Name: _ ...K""rrv1.i-.>L....H"'e"rt-"e"n"s"'te"i!!n _

Type Title: _-"S"it"-e"D"'ir"e"'ct"'o!!r _

Date: ..!M"ar""'ch!!.£Z8.,.-'Z"'O,,03L- _

Issued as a final order ofthe Commissioner ofthe Deparunent ofEnvironmentaJ

,1~; I .4- Protection on __--'-p-+,.~=-'---_'._"_. :--. 2003.

7

Arthur J Rocque, Jr.

Com ssioner

CITY OF GROTON LAND RECORDS

MAILED CERTIFIED MAIL,

RETIJRN RECEIPT REQUESTED

Cenified Document No.